Document name: Safeguarding Adults at Risk Abuse or Neglect Document type: Policy What does this policy replace? Update of previous SWYPFT safeguarding vulnerable adults policy Staff group to whom it applies: All staff within the Trust Distribution: The whole of the Trust How to access: Intranet and internet Issue date: February 2015 Next review: February 2017 Approved by: Executive Management Team Developed by: Sue Hanks Director leads: Director Of Nursing Compliance and Safety Contact for advice: Safeguarding 328630 Team Tel: from 01924 Contents Page 1 1.0 Introduction 2.0 Purpose 2 3.0 Duties 4 4.0 Definitions 7 5.0 Procedure 10 6.0 Prioritisation of Work 13 7.0 Scope of the Policy 15 8.0 Consultation, Approval and Ratification Process 15 9.0 Review & Revision Arrangements 16 Including Version Control 10.0 Dissemination and Implementation 16 11.0 Monitoring Compliance 17 12.0 References 18 13.0 Associated Documentation 18 Appendix A Appendix B Appendix C 1.0 1.1 Introduction South West Yorkshire Foundation Trust is an organisation which is clear in its mission statement that our role is to enable people (children, young people and adults) to reach their potential and live well in the community. Our ultimate aim is to enable individuals to make decisions in relation to their own health outcomes. The Safeguarding Team support the Trust Transformation process and the principles of the Recovery Model. The Safeguarding Team acknowledge that ‘each unique individual has a unique view on what living well means to them. Our role is to help people gain greater control and responsibility for their future’ http://nww.swyt.nhs.uk/transformation/Pages/Recovery.aspx The National agendas that are shaping the future of the NHS, such as the Department of health initiative post Winterbourne to reduce restrictive physical interventions are reflected in the ethos and practices of the safeguarding team. The Skills for Care document (2013) Supporting staff working with people who challenge services. Guidance for employers suggests ‘safeguarding leads’ assist in considering situations where restrictions or interventions are used which may or may not be ethically or legally justified’. Some of the lessons learnt from Mid Staffordshire NHS Foundation Trust Public Inquiry (2013) refer to ‘no tolerance of non-compliance, openness and transparency, a level playing field of accountability and strong support for leadership roles. This policy is underpinned by these views and directs staff to the frameworks to assist them to deliver compassionate, individualized care. There will be times in an individual’s life when they are at risk from abuse or neglect. It is an individual’s right to make their own lifestyle choices but there will be certain times they will need extra support, for example safeguarding is mainly aimed at people with care and support needs who maybe in vulnerable circumstances and at risk of abuse or neglect by others. This may be when they are deemed not to have capacity or there may be suggestion of coercion by a third party. We will work to prevent abuse and neglect but where abuse or neglect is suspected or known, staff will understand their obligations (and under which circumstances) to raise a concern to the local authority to allow them to execute their responsibilities. 1.2 SWYPFT are committed to ensure that the principles of safeguarding: empowerment, prevention, proportionality, protection, partnership and accountability are pivotal in decision making and in the coproduction of plans of care. 1.3 Empowerment of the service user and ensuring that the service user’s wishes and their aspired outcomes are at the heart of any ‘decision making’ process is a ‘constant’ underpinning all this policy. Bearing this is mind staff need also to be aware of and act in accordance with the principles laid down in the 1 Mental Capacity Act (2005) and SWYPFT guidance on how to interpret and document this legislation. www.swyt.nhs.uk/mental-health-law/documents/mca-cp.pdf 1.4 The local authority is the lead agency with regards to Safeguarding Adults from abuse or neglect. South West Yorkshire Foundation Trust are committed to providing safe services through the frameworks of CQC Fundamental Standards of Quality and Safety regulation 13. 1.5 South West Yorkshire Partnership NHS Foundation Trust accepts the principles laid down within the West Yorkshire’s Multi-Agency Safeguarding Adults policy and procedures 2013 and the South Yorkshire Policy and Procedures 2014 documents, and is committed to working in partnership. 1.6 The Trust expects each member of staff to work in partnership with service users and other agencies who have signed up to the Multi-Agency Policies and Procedures. This document is written to support staff in discharging their duty to prevent abuse occurring where possible, recognise and identify abuse and effectively report abuse as identified within the appropriate local authority policy and procedure. This document describes how the organisation will provide a clear process to ensure that staff are aware of and know how to implement policies, protocols and guidelines and how to access the current version with certainty. It describes how the procedural document will be monitored and reviewed. 2.0 Purpose 2.1 The purpose of the policy is for staff to understand safeguarding within the context of legislation, compliance and professional responsibility. They will understand the requirement to work within the Multiagency Policies and Procedures and that the CQC framework offers an additional framework within which to work. 2.2 The policy replaces the previous single agency policy and signposts to two updated Multiagency policies. This policy is developed in the context of (i) Explicit Safeguarding Responsibilities for the local authority as lead provider are now outlined in the Care Act (2014) (implemented as per April 2015). There is a duty to refer any suspected or known abuse to the local authority where the following conditions apply:- The Care Act (2014) (Part 1 Section 42) 1. Enquiry by Local Authority This section applies where a Local Authority has reasonable cause to suspect that an adult in its area (whether or not ordinarily resident there)a) has needs for care and support (whether or not the authority is meeting any of those needs) 2 b) is experiencing or is at risk of abuse or neglect and c) as a result of those needs is unable to protect himself or herself against the abuse or neglect or risk of it 2.3 The local authority must make (or cause to be made) whatever enquiries it thinks necessary to enable it to decide whether any action should be taken in the adult’s case. The Multiagency policies and procedures provide comprehensive guidance for staff this policy will ensure that all staff understands that the local authority has the legal duty to investigate allegations of abuse or neglect and are aware the correct process for raising a concern into the local authority. 2.4 The purpose of this policy is to provide a clear and effective system for staff to follow in order to safeguard adults at risk from abuse or neglect, where abuse has occurred, to prevent or minimise the risk of future abuse. The main objectives are to:Ensure there is an effective process for staff to follow ensuring the guidance laid down within this policy is contemporary to each local authority policy on the Safeguarding Adults at Risk of Abuse or Neglect. Ensure staff work within the local authority Multi-Agency Policy and Procedure relevant to their working locality. Describe how this policy will be monitored. In addition the organisation has a duty to ensure that adults are safeguarded from abuse the legal framework are required to adhere to is the Fundamental Standards of Quality and Safety (Care Quality Commission 2015). This policy makes the duties of staff groups explicit against these standards and outlines internal processes that sit outside the multiagency safeguarding adults policy framework CQC compliance -Fundamental Standards of Quality and Safety regulation 13. 3.0 Duties The Trust has a Duty of Care in relation to safeguarding adults from abuse or neglect. 3.1 Duties within the Organisation Executive Management Team (EMT) The Executive Management team approves this policy and in doing so has signed up to the principles of the implementation of the local authorities’ Safeguarding Adults at risk of abuse or neglect policies. Lead Director 3 The Director of Nursing, Clinical Governance and Safety is the lead director for this policy and the Multi-Agency Safeguarding Adults at risk of abuse or neglect policies. The Director of Nursing, Compliance and Safety and the Assistant Director of Nursing have the responsibility of attending the MultiAgency Safeguarding Boards. Their role is to ensure decisions made by the Multi-Agency Safeguarding Boards are incorporated into the process for the development of this procedural document. Director members of the Safeguarding Board will nominate relevant staff to contribute to Safeguarding Adults Reviews (formerly Serious Case Reviews) as necessary. The lead Director will ensure partner agencies are aware of who to contact in relation to safeguarding concerns (Designated Adult Safeguarding Manager). Assistant Director The Assistant Director has responsibility for the management and governance of the Safeguarding team, whilst supporting the Director to deliver on the Safeguarding agenda for the Trust. Directors District Service Directors have the lead in ensuring this policy is cascaded to Business Delivery Units (BDUs) and Trustwide Action Groups (TAGS). The same groups will also have a role in implementing the procedural document. Specialist Staff The Specialist Adviser for Vulnerable Adults with support from the safeguarding team is responsible for the co-ordination of the development of the policy and its implementation through the Trust Action Group and in addition has a lead on the development of training which supports the implementation of this document. The Specialist Adviser is responsible for ensuring Directors are made aware of issues that occur within their localities as they arise. The Specialist Adviser scans all incidents reported on the DATIX system and alerts the Directors to any trends. The Specialist Adviser will provide reports to the BDUs throughout the year that will include lessons learnt, performance management and changes to policy and procedures. Quarterly reports are submitted to the Executive Management Team (EMT) and board within the compliance and quality report and an annual report that incorporates the above information will be submitted to the Clinical Governance Committee for scrutiny as a sub group of the Trust Board by the Specialist Adviser for Vulnerable Adults. 4 Service Managers Service managers will ensure the policy is implemented in practice. They will ensure positive and reactive strategies ensure people are safeguarded thereby enacting the requirements of this policy. Professional / Clinical Leads and Matrons All professional /clinical Leads and matrons have a leadership role within safeguarding, first and foremost ensuring high quality care and service delivery for children, young people and adults. They should be able to advise on the referral processes and signpost staff to the safeguarding team or local authority as required. They can provide a first level of advice where they feel able, referring onto the safeguarding team due to a presenting issue or complexity of the case. Clinical Leads and Matrons should have robust oversight of Patient Safety Issues and ensure that appropriate concerns are raised into safeguarding. Particular areas for consideration are nutrition, falls, and pressure ulcer prevention, managing violence and aggression and transition pathways. Practice Governance Coaches Practice Governance Coaches will enable staff to deliver on the care agenda which supports safeguarding. They will do this by supporting staff to proactively assess and plan for care, ensuring risk management is intrinsic to process. In addition practice governance coaches can remind staff of policies which facilitate high quality care and manage risk, Did Not Attend policy, transitions policies etc. They have a role in identifying barriers to the achievement of those factors and enable them to be effectively raised, providing support for problem solving where required. Practice Governance Coaches will advise staff on raising concerns into safeguarding, and support person centred approaches by coaching people through the decision making process. Practice Governance Coaches will advise staff to contact the safeguarding team when they feel that they cannot advise appropriately due to the presenting issue or complexity of the case. Practice Governance Coaches will horizon scan across the organisations to risk assess any temporary deficiencies in care pathways or partnerships, (reduced leadership, management oversight, sickness, high volume of service demand) and ensure robust planning arrangements are put in place to manage the risk for service users. Staff 5 All staff are aware of this policy and the Multi-Agency Safeguarding Adults policy and procedures and the impact it has on their practice. If any members of staff are aware of difficulties in following the procedural document they must alert their line manager as soon as is practical. It is everyone’s business to report abuse. Staff members continue to have responsibility to safeguard the person and reduce risk i.e. via care plans and participation in the safeguarding process. Registered professionals also need to be aware of their accountability and registration requirements as stipulated by their governing bodies ie Nursing and Midwifery Council, HCPC etc Information regarding ‘Whistleblowing’ Policy. ‘whistleblowing’ is highlighted in the Trust’s 3.2 Consultation and Communication with Stakeholders 3.3 The organisation recognises that procedural documents need to be developed in consultation with a range of stakeholders. Stakeholders have included Yorkshire Police, Members of Safeguarding Boards, and Mid-Yorkshire Hospital Trust and specialist commissioners . Approval of this Document The executive management team is responsible for final approval of all Trust procedural documents. The Director of Nursing, Innovation and Compliance is responsible for placing this procedural document on the EMT agenda. Multi Agency procedural documents have been approved by the Safeguarding Boards of which the Trust is a member. 4.0 Definitions Definition Procedural document This includes any policy, procedure, protocol or guideline that is trust wide. Multi-Agency documents Procedural documents the trust has signed as a partner agency to use. This includes the local authority Safeguarding Adults at Risk of abuse of neglect Policy and Procedures for both West Yorkshire and South Yorkshire. Adult at Risk of abuse or harm (formerly Vulnerable Adult) Adult at risk The safeguarding duties apply to an adult who: of abuse or • has needs for care and support (whether or not the local authority is meeting any of neglect those needs) and; •is experiencing, or at risk of, abuse or neglect; and 6 •as a result of those care and support needs is unable to protect themselves from either the risk of, or the experience of abuse or neglect. (Chapter 14 Page 229 Care Act (2014) Guidance replaces the Department of Health (2000) No Secrets Document ) Abuse is a violation of an individual’s human and civil rights by another person or persons (No Secrets 2000). This may include physical, sexual, psychological, financial or discriminatory abuse. The Care Act 2015 state staff should not limit their views of what constitutes abuse or neglect. Abuse Raising concern a Informing relevant manager that a person: has been abused, is being abused or is at risk of being abused Domestic Abuse The Government definition of domestic violence and abuse is: 'Any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse between those aged 16 or over who are or have been intimate partners or family members regardless of gender or sexuality. This can encompass, but is not limited to, the following types of abuse: psychological, physical, sexual, financial, emotional https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/142701/guideon-definition-of-dv.pdf Deprivation of Liberty Safeguards Dols The deprivation of liberty safeguards were introduced to provide a legal framework around the deprivation of liberty. Specifically, they were introduced to prevent breaches of the European Convention on Human Rights (ECHR) such as the one identified by the judgment of the European Court of Human Rights (ECtHR) in the case of HL v the United Kingdom3 (commonly referred to as the ‘Bournewood’ judgment). And more recently the Cheshire West verdict. http://nww.swyt.nhs.uk/mental-health-law/Pages/Deprivation-of-LibertySafeguards.aspx PREVENT Prevent is part of the Home Office and Department of Health agenda. The aim of Prevent is to stop people from becoming terrorists or supporting terrorism. Three national objectives have been identified for the Prevent strategy: •Objective 1: respond to the ideological challenge of terrorism and the threat we face from those who promote it •Objective 2: prevent people from being drawn into terrorism and ensure that they are given appropriate advice and support •Objective 3: work with sectors and institutions where there are risks of radicalisation which we need to address. 7 The health sector contribution to Prevent will focus primarily on Objectives 2 and 3. Safeguarding Each local authority must establish a Safeguarding Adults Board (an “SAB”) for its Board (SAB) area. (2)The objective of an SAB is to help and protect adults in its area in cases of the kind described in section 42(1). http://www.legislation.gov.uk/ukpga/2014/23/section/43/enacted The Board consists of representatives from different agencies: such as police, Local Authority, Ambulance service, Fire and Rescue, Health, Housing, Clinical Commissioning Group CQC Fundamental Standards of quality and Safety 13.—(1) Service users must be protected from abuse and improper treatment in accordance with this regulation. (2) Systems and processes must be established and operated effectively to prevent abuse of service users. (3) Systems and processes must be established and operated effectively to investigate, immediately upon becoming aware of, any allegation or evidence of such abuse. (4) Care or treatment for service users must not be provided in a way that— (a) includes discrimination against a service user on grounds of any protected characteristic (as defined in section 4 of the Equality Act 2010) of the service user, (b) includes acts intended to control or restrain a service user that are not necessary to prevent, or not a proportionate response to, a risk of harm posed to the service user or another individual if the service user was not subject to control or restraint, (c) is degrading for the service user, or (d) significantly disregards the needs of the service user for care or treatment. (5) A service user must not be deprived of their liberty for the purpose of receiving care or treatment without lawful authority. (6) For the purposes of this regulation— “abuse” means— (a) any behaviour towards a service user that is an offence under the Sexual Offences Act 2003(1), (b) ill-treatment (whether of a physical or psychological nature) of a service user, (c) theft, misuse or misappropriation of money or property belonging to a service user, or (d) neglect of a service user. (7) For the purposes of this regulation, a person controls or restrains a service user if that person— (a) uses, or threatens to use, force to secure the doing of an act which the service user resists, or b) restricts the service user’s liberty of movement, whether or not the service user resists, including by use of physical, mechanical or chemical means. Single A single agency policy which states the high level requirements for safeguarding and Agency signposts staff to the relevant procedures Safeguarding 8 Policy Mental The Mental Capacity Act 2005 (the Act) aims to empower and protect people who Capacity Act may not be able to make some decisions for themselves. It also enables people to (2005) MCA plan ahead in case they’re unable to make important decisions in the future. The Act applies to anyone aged 16 or over in England and Wales. If a person lacks the capacity to make decisions, and they have not made advance plans for this situation, the Act allows someone else to make that decision for them. A person is deemed to lack capacity if they cannot, due to their illness or disability: •understand information given to them to make a decision •retain that information long enough to be able to make the decision •use or weigh up the information to make the decision •communicate their decision http://nww.swyt.nhs.uk/mental-health-law/Pages/Mental-Capacity-Act.aspx Datix The Trust patient safety reporting system. All incidents that have had a Safeguarding alert to the Local Authority required a Datix report to be completed Safeguarding The Care Act 2015 defines the circumstances under which a SAB must conduct a Adults SAR as “there is reasonable cause for concern about how the SAB, members of it or Reviews others work together to safeguard the adult and death or serious harm arose from actual or suspected abuse.” Domestic Homicide review (DHR) Domestic Homicide review means a review of the circumstances in which the death of a person aged 16 or over has, or appears to have, resulted from violence abuse or neglect by: a) A person to whom he was related to or with whom he was or had been in an intimate personal relationship, or b) A member of the same household as himself, held with a view to identifying the lessons learnt from the death. https://www.gov.uk/government/publications/revised-statutory-guidance-forthe-conduct-of-domestic-homicide-reviews 5.0 Procedure - Each step of the process is supported by local documentation or flowcharts which have been designed by the LSAB and are available via the intranet safeguarding adults’ webpage and as an 9 appendix to this policy . Following this procedure does not take the responsibility away from the staff team for keeping the person safe. Care planning and managing risk must be ongoing as usual. Reporting Abuse 5.1 All staff who observe abuse or who have a concern in relation to a service user will report those issues as soon as possible to their line manager (unless they suspect that the manager is implicated.) In such a situation they must report on to a more senior manager as soon as possible. 5.2 The line manager will, at the earliest possible opportunity, engage with the appropriate lead person within Social Services and/or the police depending on the type of concern and nature of the allegation. See “useful contacts” for the telephone numbers. (Appendix B) 5.3 If the issue appears to involve a crime the Police will be contacted as soon as possible. It is not necessary to wait for a safeguarding section 42 meeting to take place or the go ahead from a lead person. Great care must be taken to ensure evidence is not contaminated - this may require the sealing off of areas and the isolation of individuals. If it is necessary to inform the Police as a matter of urgency the line manager for that department or the on call manager should be informed as soon as possible. 5.4 Where staff are concerned that the abuse or neglect is linked to poor practice within the organisation support / guidance in relation to reporting concerns within the Trust is available within the Trust’s “Whistle Blowing” policy. 5.5 If the line manager is unclear as to the appropriate person/agency to be contacted, advice will be sought from the Trust’s Specialist Adviser for Vulnerable Adults or the safeguarding team. 5.6 Each district Multi-Agency Safeguarding policy states the process in relation to reporting, recording, and the process for dealing with alleged abuse and alerting other agencies. These local policies must always be followed. To enable staff to work within local procedures flowcharts are available on the intranet safeguarding adult’s webpage and as an appendix to this policy. 5.7 Through liaising with Social Services it will be identified who is the appropriate person to co-ordinate the safeguarding investigation process. This may be if a crime the police, Safeguarding Co-ordinator or a Social Worker as a section 42 enquiry depending on the circumstances of the allegation. 5.8 An incident report form (electronic or paper) will be completed by the person who is first alerted to the potential abuse or neglect. This form must be completed to indicate what happened and what action has been taken i.e. reported on to social services and if necessary also reported to the Police if a crime is suspect. Where an incident doesn’t reach the threshold for a safeguarding concernl to be made it must be dealt with via staff intervention and case management. 10 All allegations of abuse will be reported as an incident and graded. For example, if a patient is alleged to have suffered physical harm by a member of staff this should be initially graded as serious amber level 4 or severe red level 5. It is advised that a body-map must be completed on Rio or system one of any physical harm noting i.e. bruising, colouring location etc. This is located on RIO in ‘Case Record’ then onto ‘assessments’ on the right hand side of the screen and the physical examination form is right at the bottom of the listing. Click run if a popup box appears, it takes a while to load. Within System one the body map is situated under medical records. If there is no immediate evidence of any physical harm, the allegation of abuse, may require a lower grading after review. All allegations of abuse, including allegations of service users abusing other service users, must be reported as an incident and the severity graded. All allegations against staff must be reported through this system and line manager’s informed for consideration and action through the disciplinary process. Consideration must be given to threshold. Incidents that result in harm will always be taken through the Safeguarding Adults at risk of abuse or neglect procedure. Allegations or incidents of abuse that appear to be linked to the person’s level of understanding through illness or learning disability, that have resulted in no harm, will be graded as a green incident. These incidents will be given consideration as, if left to continue, they may result in poor care standards and institutional abuse. One person’s behaviour having a detrimental effect on others will be addressed via staff intervention and case management. The service manager must consider the need to report under the Multi-Agency Safeguarding policy. This is not always appropriate if care plans and risk management has taken place. Where abuse is suspected and it involves an allegation against staff or is an allegation which has the potential to be an amber or red incident consideration should be given by the line manager to informing the Director of Nursing via the specialist advisor, in these instances there is an obligation to inform the Care Quality Commission directly 5.13 Multi-Agency policies will be followed. Each Safeguarding Board has its own Multiagency Policy that staff are required to follow West Yorkshire multi agency safeguarding adults policy and procedure 2013 (Wakefield Kirklees and Calderdale) http://www.kirklees.gov.uk/community/yourneighbourhood/crimeSafety/pdf/safeguardingAdult PolicyProcedures.pdf South Yorkshire multi agency safeguarding adults Policies and Procedures 2014 http://www.proceduresonline.com/southyorks/sab/ 11 5.20 Allegations or concerns relating to Trust Staff The above process will be followed in all cases where it is alleged a member of staff has breached their position of trust. 5.21 5.22 Actions will be guided by the procedures set out within the Trust’s Disciplinary procedures. Staff must ensure they maintain professional boundaries at all times, further information is available via the Sexual Relationships policy. 5.23 Staff and others involved in caring for service users are not able to benefit financially or inappropriately gain from a person who uses services; unless it is in line with their service’s arrangements, which should take account of other relevant professional guidance. Therefore all gifts should be refused unless it causes distress to the service user to do so. In such a case the service manager should be informed of the gift to enable appropriate action to be taken. 5.24 Staff should not be involved in writing wills or bequests of people who use services. 5.25 Staff should not use the property of people who use services for personal use. 5.26 Staff must not borrow money from, or lend money to, people who use services. Nor should they sell or dispose of goods belonging to people who use services for their own gain. 5.27 The disciplinary process of investigation of staff abuse will be a joint one with the investigator and a senior member of staff supported by Human Resources and the Specialist Advisor - Vulnerable Adults. 5.28 If at any time the process indicates that a crime may have taken place the investigation must be stopped until the police have been contacted and advice on how to proceed has been received. This advice will be documented and included within the report of the findings. 5.29 Any staff who have been identified as abusing their position of trust or intentionally causing harm to service users will be reported via the Disclosure and Barring Service process as part of the disciplinary process. https://www.gov.uk/disclosure-barring-service-check/overview 5.30 Reporting abusers to the DBS It is the duty of the General Manager who chairs the disciplinary procedure to make a referral to DBS immediately on making the decision to discipline a member of staff for abuse. This process will be 12 supported by the safeguarding adults’ specialist adviser or the safeguarding children’s lead nurse. Jobs that involve caring for, supervising or being in sole charge of children or adults may require an ‘enhanced DBS check with a check of the barred lists’. This will check whether someone’s included in the 2 DBS ‘barred lists’ (previously called ISA barred lists) of individuals who are unsuitable for working with: Children, Adults. People on the barred lists can’t do certain types of work. There are specific rules for working in places where there are children - known as working in a regulated activity with children. These are different than the rules for regulated activities for adults. 5.31 Where individuals choose to leave the organisation prior to an investigation the Trust must complete the process and, wherever necessary, make the necessary referral to DBS Employers must refer someone to DBS if they: have terminated their employment because they harmed someone dismissed them or removed them from working in regulated activity because they might have harmed someone were planning to sack them for either of these reasons, but they resigned first 5.32 The Assistant Director of Nursing Compliance and Safety is to be informed and will take action to report professional staff to their governing body if they breached their Code of Practice 5.33 Domestic Abuse Staff may become aware of abuse occurring within domestic settings between partners or other family members. In such cases it may be necessary to access both the Multi Agency Safeguarding Adults’ policy and the Domestic Abuse Policy. It is possible for both these policies to be in use simultaneously. 6.0 Prioritisation of Work This protocol is prioritised by Joint investigation into the provision of services for people with learning disabilities at Cornwall Partnership NHS Trust. Healthcare Commission (2006) Investigation into matters arising from care on Rowan Ward, Manchester Mental Health and Social Care Trust Commission for Health Improvement (2003) 13 6.1 Risk identified from Datix reports which clearly illustrate the need for staff to be aware of how to report abuse. The implementation of Local Authority Multi Agency Safeguarding Policies. The Mid Staffordshire NHS Foundation Trust Public Inquiry Chaired by Robert Francis QC HC 947 Report of the Mid Staffordshire NHS Foundation Trust Public Inquiry February (2013) Executive Summary Transforming care: A national response to Winterbourne View Hospital Department of Health Review: Department of Health (2012) Treating patients and service users with respect, dignity and compassion Department of Health 2013 Domestic violence and abuse: how health services, social care and the organisations they work with can respond effectively NICE (February 2014) http://www.nice.org.uk/Guidance/PH50/chapter/glossary# Care Act Chapter 23 (2014) Care and support Statutory Guidance Department of Health 2014 Identification of Stakeholders The following identifies some of the individuals, groups and organisations that the Trust has consulted with, but the list is not exhaustive. Stakeholder Possible level of involvement Executive management team Consultation, final approval Directors Allocated lead, development, consultation, receipt, circulation BDU’s Development, consultation, dissemination, implementation, monitoring Specialist Adviser for Vulnerable Adults Development, consultation, dissemination, implementation Service users/carers Development, consultation 14 Professional groups /leadership Child Protection Lead / Nurse Development, consultation, dissemination, implementation Consultants Safeguarding Adults lead nurse Clinical Governance Coaches Trustwide action groups MAV TAG, Development, consultation, dissemination, H&S TAG, Safeguarding Adults TAG implementation Local authority Development, consultation Police Development, consultation Other NHS trusts Mid Yorkshire Trust, Development, consultation Wakefield PCT 6.2 Equality impact assessment – please see Appendix C 7.0 Scope of the Policy All Trust Staff It is the duty of all Trust Staff to work within this policy in the safeguarding of adults at risk of harm or abuse. 8.0 Consultation, Approval and Ratification Process 8.1 Consultation Process Safeguarding Adults TAG, Strategic Sub Group, Health and Safety Tag and Partner Agencies have been consulted re the development of this polocy. For this document the executive management team has been consulted. 8.2 Ratification Process This document will be ratified by the EMT. 9.0 Review and Revision Arrangements including Version Control 9.1 Process for Reviewing a Procedural Document This document will be reviewed in 2 years unless multi agency policy or Legislation / Government guidance indicates need for changes to be made. 15 9.2 Version Control This document is Version 5 Draft 4. Changes relate to introduction of Legislation Integrated governance manager The Integrated governance manager will be responsible for document control including the recording, storing and controlling of current procedural documents and archiving arrangements. 10.0 Dissemination and Implementation & Training Requirements 10.1 Dissemination This document will be available via the Trust intranet and website via the document store. 10.2 If local teams download procedural documents, they will develop a written system for keeping this up to date that must be approved by: Implementation of this Policy This document will be implemented as follows Via the Team Brief which will alert staff of this version New staff will be informed at induction of the policy and how to access it. The Policy and Safeguarding Policies will be available via the Trust intranet 10.3 Training Requirements The Trust has identified that the implementation of this policy will take place via basic awareness training. This is for all staff throughout the Trust and can be accessed via the on line induction, which links to the Safeguarding Adults workbook (level 1). It is mandatory training for all staff. Staff who work in direct contact with service users who are seen as potentially adults at risk from abuse or neglect will also undertake level 2 training. Staff must ensure they keep up to date by accessing refresher training on a 3 yearly basis. BDU’s are responsible for identifying those staff who are in direct contact with adults and ensuring they have access to training. All staff who have face to face contact with service users must discuss at appointment and at appraisal their need for safeguarding training. It is the responsibility of the individual and manager to ensure that staff have the requisite competencies to carry out their role. Further advice and support can be obtained 16 from the specialist advisor and details of training can be accessed via the training strategy and intranet pages. Staff who work as safe guarding co-ordinators should ensure they can carry out their role when managing safeguarding referrals by ensuring they access the local authority training for this role The PREVENT strategy (preventing radicalisation) also comes under the remit of safeguarding within the Trust. Staff need to be aware of the PREVENT policy on the intranet for guidance and training requirements. This information can be updated / refreshed as part of the Safeguarding Adults Training level 2 refresher. 11.Monitoring Compliance This policy meets the external requirements Care Quality Commission Safeguarding service users from abuse and improper treatment (Regulation 13): Monitoring Compliance and Effectiveness Monitoring and analysis of routine reports – e.g. incident reports, performance reports, training uptake will be reported to the EMT. Audit of the Trust Datix form will take place on an ongoing basis; feedback will be given to individual staff as necessary. Accessing statistical information from local authority leads in relation to concerns received on an annual basis. o The standard will be: o All staff will follow this policy if they see or suspect abuse. o Formal audits of the process will occur occasionally as commissioned by the lead director. This could be delivered by internal audit or the clinical governance support team. 12.0 References No Secrets – Guidance on the developing of multi agency policies and procedures to protect vulnerable adults from abuse DoH (2000) Investigation into matters arising from the care on Rowan ward Manchester Mental Health and Social Care Trust. Commission for Health Improvement (2003) Joint investigation into the provision of services for people with learning disabilities at Cornwall Partnership NHS Trust. Healthcare Commission (2006) The Mid Staffordshire NHS Foundation Trust Public Inquiry Chaired by Robert Francis QC HC 947 Report of the Mid Staffordshire NHS Foundation Trust Public Inquiry February (2013) Executive Summary Transforming care: A national response to Winterbourne View Hospital Department of Health Review: Department of Health (2012) Department of Health (2013)Treating patients and service users with respect, dignity and compassion 17 Domestic violence and abuse: how health services, social care and the organisations they work with can respond effectively NICE (February 2014) http://www.nice.org.uk/Guidance/PH50/chapter/glossary# Care Act Chapter 23 (2014) Skills for Care (2013) Supporting staff working with people who challenge services. Guidance for employers Care and support Statutory Guidance Department of Health 2014 13.0 Associated Documentation Disciplinary policy April (2012) Domestic Abuse policy October (2012) Incident Reporting and Management Procedures (including Serious Incidents) Version 6 (2014) Clinical Management of Aggression and Violence policy, procedures and guidance (2012) Policy for mandatory training (2012) Whistle Blowing policy (2003) Sexual Relationship policy (2012) Safeguarding Adults multi-agency policy and procedures. Mental Capacity Act Policy and Guidance (2008) Deprivation of Liberty ‘Applying for a Deprivation of Liberty Safeguard (DoLS): The Clinical Process’ (2014) http://nww.swyt.nhs.uk/mental-healthlaw/Pages/Deprivation-of-Liberty-Safeguards.aspx PREVENT implementation Policy 18 APPENDIX A USEFUL CONTACTS None emergency Police 101 Forces disclosure unit 01924 295671 Emergency Police 999 BARNSLEY DISTRICT Adults and communities Services (to raise a concern) Tel 01226 775656 e-mail adultprotection@barnsley.gov.uk South Yorkshire Police Tel 01142 202020 or 101 non emergency KIRKLEES DISTRICT Kirklees Area Adult Protection Co-ordinator E- Mail sarah.carlile@kirklees.gov.uk Kirklees Police safeguarding unit E-mail ea.safeguaring@westyorkshire.pnn.police.uk 01924 335073/72 Gateway to Care: (to raise a concern to social services) 01484414933 Emergency number out of hours 01924 326489 WAKEFIELD DISTRICT Safeguarding Adult business Manager Tel: 01924 302149 Social Care Direct: (to raise a concern) 0345 8 503503 Wakefield Police Community Safeguarding team Tel 01924 878008 E-Mail da.safeguarding@westyorkshire.pnn.police.uk CALDERDALE DISTRICT Adult Protection team Tel 01422 393852 safeguarding.adults@calderdale.gov.uk Gateway to Care on 01422 393000 Calderdale Police: Calderdale Community Safety: 01422 318 120 Calderdale Domestic Violence/ Vulnerable Victims Co-ordinator: 01422 337 041 1 Adult Protection 01422 337041 E-mail address fa.safeguarding@westyorkshire.pnn.police.uk TRUST WIDE Safeguarding adults team Fieldhead Hospital Ouchthorpe Lane Wakefield WF1 3SP Tel 01924 328630 E-Mail Sue.hanks@swyt.nhs.uk or carol.morgan@swyt.nhs.uk Page 2 CALDERDALE INPATIENTS TEAMS SAFEGUARDING ADULTS PROCEDURE A Concern is raised re abuse The person who becomes aware of the abuse or neglect must ensure the following takes place Take immediate steps to ensure safety ie alerting others, seeking help, medical help. Continue to support victim throughout process NB all grade 4 pressure sores require an automatic raising a concern to Gateway to Care Report to line manager Consent given – inform GTC and/or police High risk incidents of harm must be reported to General Manager/Director of Nursing, Compliance and Safety immediately. Director of Nursing, Compliance and Safety to inform CQC Seeking consent to report on to GTC. or the Police. May need to assess mental capacity – document assessment The person lacks mental capacity. Report on to GTC and/or police in their best interest Consent refused. Assess risk/seriousness. If others are at risk OR if perpetrator is a member of staff or volunteer explain need and raise a concern to GTC and/or police. Raise a concern Contact GTC – share relevant information. Request which team will be allocated. (If case already known to community team inform GTC) If concern is closed ask for outcome code. If a crime is suspected Contact Police, share information, ask for log numbers. Complete RiO/Datix; include GTC/Police log number under action taken NB complete body map form if physical signs of abuse or neglect noted If the case is already known to your team ensure safeguarding procedure is followed. Ensuring locally agreed processors for logging action is followed. Risk team to forward Datix report to NPSA and CQC Gateway to Care (GTC): 01422 393000 Safeguarding Unit (Police): non emergency 01422 337041 or 101 Police (for urgent emergency response): 0845 6060606 or 999 Adviser for vulnerable adults (advice) 01924 328630 Page 3 WAKEFIELD INPATIENT AREAS SAFEGUARDING ADULTS PROCEDURE A Concern is raised re abuse The person who becomes aware of the abuse or neglect must ensure the following takes place Take immediate steps to ensure safety ie alerting others, seeking help, medical help. Continue to support victim throughout process NB all grade 4 pressure sores require an automatic concern to Social Care Direct Report to line manager Consent given – inform SCD and/or police High risk incidents of harm must be reported to General Manager/Director of Nursing Compliance and Safety immediately. Director of Nursing, compliance and safety to inform CQC Seeking consent to report on to SCD. or the Police. May need to assess mental capacity – document assessment The person lacks mental capacity. Report on to SCD and/or police in their best interest Consent refused. Assess risk/seriousness. If others are at risk OR if perpetrator is a member of staff or volunteer explain need to raise a concern to SCD and/or police. Raise concern Contact SCD– share relevant information. Request which team will be allocated. If concern is closed ask for outcome code. If a crime is suspected Contact Police, share information, ask for log numbers. Complete RiO/Datix; include SCD/Police log number under action taken NB complete body map form if physical signs of abuse or neglect noted Risk team to forward Datix report to NPSA and CQC Social Care Direct (SCD): 0345 8 503 503 Safeguarding Unit (Police): non emergency 01924 878008 Police (for urgent emergency response): 101 Adviser for vulnerable adults (advice) 01924 328630 Page 4 WAKEFIELD COMMUNITY TEAMS SAFEGUARDING ADULTS PROCEDURE A Concern is raised re abuse The person who becomes aware of the abuse or neglect must ensure the following takes place Take immediate steps to ensure safety ie alerting others, seeking help, medical help .Continue to support victim throughout process NB all grade 4 pressure sores require automatic concern to be raised to Social Care Direct Report to line manager Consent given – inform SCD (or open a safeguarding referral) and/or police High risk incidents of harm must be reported to General Manager/ Director of Nursing Compliance and Safety immediately. Director of Nursing, Compliance and Safety to inform CQC Seeking consent to report on to SCD (or open a safeguarding referral). or the Police. May need to assess mental capacity – document assessment The person lacks mental capacity. Report on to SCD (or open a safeguarding Sec 42) and/or report to police in their best interest Consent refused. Assess risk/seriousness. If others are at risk OR if perpetrator is a member of staff or volunteer explain need to raise concern to SCD (or open a safeguarding Sec 42) and/or police. Raise a concern Contact SCD – share relevant information. Request which team will be allocated. If concern is closed ask for outcome code. If a crime is suspected Contact Police, share information, ask for log numbers. Complete RiO/Datix; include SCD/Police log number under action taken NB complete body map form if physical signs of abuse or neglect noted Risk team to forward Datix report to NPSA and CQC Social Care Direct (SCD): 0345 8 503 503 Safeguarding Unit (Police): non emergency 01924 878008 Police (for urgent emergency response): 101 Adviser for vulnerable adults (advice) 01924 328630 Page 5 CALDERDALE COMMUNITY TEAMS SAFEGUARDING ADULTS PROCEDURE A Concern is raised re abuse The person who becomes aware of the abuse or neglect must ensure the following takes place Take immediate steps to ensure safety ie alerting others, seeking help, medical help. Continue to support victim throughout process NB all grade 4 pressure sores require an automatic concern to Gateway to Care Report to line manager Consent given – inform GTC and/or police High risk incidents of harm must be reported to General Manager/ Director of Nursing, Compliance and Safety immediately. Director of Nursing, Compliance and Safety to inform CQC Seeking consent to report on to GTC. or the Police. May need to assess mental capacity – document assessment The person lacks mental capacity. Report on to GTC and/or police in their best interest Consent refused. Assess risk/seriousness. If others are at risk OR if perpetrator is a member of staff or volunteer explain need and refer to GTCand/or police. Raise a concern Contact GTC – share relevant information. Request which team will be allocated. (If case already known to community team inform GTC) If concern is closed ask for outcome code. If a crime is suspected Contact Police, share information, ask for log numbers. Complete RiO/Datix; include GTC/Police log number under action taken NB complete body map form if physical signs of abuse or neglect noted If the case is already known to your team ensure safeguarding procedure is followed. Ensuring locally agreed processors for logging action is followed. Risk team to forward Datix report to NPSA and CQC Gateway to Care (GTC): 01422 393000 Safeguarding Unit (Police): non emergency 01422 337041 or 101 Police (for urgent emergency response): 0845 6060606 or 999 Adviser for vulnerable adults (advice) 01924 328630 Page 6 KIRKLEES COMMUNITY TEAMS SAFEGUARDING ADULTS PROCEDURE A Concern is raised re abuse The person who becomes aware of the abuse or neglect must ensure the following takes place Take immediate steps to ensure safety ie alerting others, seeking help, medical help. Continue to support victim throughout process NB all grade 4 pressure sores require an automatic concern to Gateway to Care Report to line manager Consent given – inform GTC and/or police High risk incidents of harm must be reported to General Manager/ Director of Nursing, Compliance and Safety immediately. Director of Nursing, Compliance and Safety to inform CQC Seeking consent to report on to GTC. or the Police. May need to assess mental capacity – document assessment The person lacks mental capacity. Report on to GTC and/or police in their best interest Consent refused. Assess risk/seriousness. If others are at risk OR if perpetrator is a member of staff or volunteer explain need and raise a concern to GTC and/or police. Raise a concern Contact GTC – share relevant information. Request which team will be allocated. (If case already known to community team inform GTC) If concern is closed ask for outcome code. If a crime is suspected Contact Police, share information, ask for log numbers. Complete RiO/Datix; include GTC/Police log number under action taken NB complete body map form if physical signs of abuse or neglect noted If the case is already known to your team ensure safeguarding procedure is followed. Ensuring locally agreed processors for logging action is followed. Risk team to forward Datix report to NPSA and CQC Gateway to Care (GTC): 01484 414933 Safeguarding Unit (Police): none emergency 01924 335073 or 101 Police (for urgent emergency response): 0845 6060606 or 999 Adviser for vulnerable adults (advice) 01924 328630 Page 7 BARNSLEY - SAFEGUARDING ADULTS PROCEDURE A concern is raised re abuse The person who becomes aware of the abuse or neglect must ensure the following takes place Take immediate steps to ensure safety i.e. alerting others, seeking help, medical help. Continue to support victim throughout process NB all grade 4 pressure sores require an automatic concern to be raised to adult protection Report to line manager, Clinical lead, Matron or Safeguarding Manager Seek consent to report to: adultprotection@barnsley.gov.uk or the Police Follow local process by completing form 1 You may need to assess mental capacity – document assessment Consent refused - Assess risk/seriousness. If others are at risk OR if perpetrator is a member of staff or volunteer, explain need and raise a concern to adultprotection@barnsley.gov.uk and/or police. Make an alert High risk incidents of harm must be reported to General Manager/Director of Nursing, Compliance and Safety immediately. Director of Nursing Compliance and Safety to inform CQC Risk team to forward Datix report to NPSA and CQC The person lacks mental capacity. Report: adultprotection@barnsley .gov.uk and/or police in their best interest Consent given: inform adultprotection@ barnsley.gov.uk and/or police Contact Adult Protection – share relevant information. Request which team will be allocated. (If case already known to community team – inform them) If concern is closed ask for outcome code. If a crime is suspected contact Police, share information, ask for log numbers. Complete RiO/Datix; include any log number under action taken complete body map form if physical signs of abuse or neglect noted If the case is already known to your team -ensure safeguarding procedure is followed, including locally agreed processors for logging action Safeguarding Vulnerable Adults Team, Social Services: 01226 775656 Police non emergency: 101 Police for urgent emergency response: 999 Adviser for vulnerable adults (advice): 01924 328630 Page 8 FORENSIC SERVICES SAFEGUARDING ADULTS PROCEDURE A Concern is raised re abuse The person who becomes aware of the abuse or neglect must ensure the following takes place Take immediate steps to ensure safety ie alerting others, seeking help, medical help. Continue to support victim throughout process NB all grade 4 pressure sores require an automatic concern to Social Care Direct Report to line manager Consent given – inform SCD and/or police High risk incidents of harm must be reported to General Manager/ Director of Nursing Compliance and Safety immediately. Director of Nursing, Compliance and Safety to inform CQC Seeking consent to report on to SCD. or the Police. May need to assess mental capacity – document assessment The person lacks mental capacity. Report on to SCD and/or police in their best interest Consent refused. Assess risk/seriousness. If others are at risk OR if perpetrator is a member of staff or volunteer explain need and to raise a concern to SCD and/or police. Raise a concern Contact SCD – share relevant information. Request which team will be allocated. If concern is closed ask for outcome code. If a crime is suspected Contact Police, share information, ask for log numbers. Complete RiO/Datix; include SCD/Police log number under action taken NB complete body map form if physical signs of abuse or neglect noted Risk team to forward Datix report to NPSA and CQC Social Care Direct (SCD): 0345 8 503 503 Safeguarding Unit (Police): non emergency 01924 878008 or 101 Adviser for vulnerable adults (advice) 01924 328630 Page 9 KIRKLEES INPATIENT AREAS SAFEGUARDING ADULTS PROCEDURE A Concern is raised re abuse The person who becomes aware of the abuse or neglect must ensure the following takes place Take immediate steps to ensure safety ie alerting others, seeking help, medical help. Continue to support victim throughout process NB all grade 4 pressure sores require an automatic rconcern to Gateway to Care Report to line manager Consent given – inform GTC and/or police High risk incidents of harm must be reported to General Manager/ Director of Nursing, Compliance and Safety immediately. Director of Nursing, Compliance and Safety to inform CQC Seeking consent to report on to GTC. or the Police. May need to assess mental capacity – document assessment The person lacks mental capacity. Report on to GTC and/or police in their best interest Consent refused. Assess risk/seriousness. If others are at risk OR if perpetrator is a member of staff or volunteer explain need and to raise a concern to GTCand/or police. Raise a concern Contact GTC – share relevant information. Request which team will be allocated. (If case already known to community team inform GTC) If concern is closed ask for outcome code. If a crime is suspected Contact Police, share information, ask for log numbers. Complete RiO/Datix; include GTC/Police log number under action taken NB complete body map form if physical signs of abuse or neglect noted If the case is already known to your team ensure safeguarding procedure is followed. Ensuring locally agreed processors for logging action is followed Risk team to forward Datix report to NPSA and CQC Gateway to Care (GTC): 01484 414933 Safeguarding Unit (Police): non emergency 01924 335073 or 101 Police (for urgent emergency response): 0845 6060606 or 999 Adviser for vulnerable adults (advice) 01924 328630 Page 10 Appendix B - Equality Impact Assessment Tool To be completed and attached to any policy document when submitted to the Executive Management Team for consideration and approval. Date of Assessment: ___11.12.14_____________________________ Equality Impact Assessment Questions: Evidence based Answers & Actions: 1 Name of the document that you are Equality Impact Assessing Safeguarding adults at Risk from Abuse and neglect policy 2 Describe the overall aim of your document and context? The overall aim of the Policy is to describe the Trust’s approach to the safeguarding of adults Who will benefit from this policy/procedure/strategy? All service users and staff Who is the overall lead for this assessment? Director of Nursing, compliance and safety 3 4 Who else was involved in conducting this assessment? The safeguarding team 5 Have you involved and consulted service users, carers, and staff in developing this policy/procedure/strategy? People involved included staff in BDU’s LA safeguarding leads, volunteers What did you find out and how have you used this information? Change of terminology 6 What equality data have you used to inform this equality impact assessment? Datix data 7 What does this data say? The data indicates that staff have to be able to identify abuse and know how to work in partnership to protect those at risk 8 Taking into account the information gathered above, could this policy /procedure/strategy affect any of the following equality group unfavourably: Yes/No 8.1 Race Yes Those who are suffering from racial abuse will benefit from staff understanding this policy 8.2 Disability yes Those seen as vulnerable due to disability will be better supported by staff being awre of this policy 8.3 Gender No Page 11 Equality Impact Assessment Questions: 8.4 Age yes Evidence based Answers & Actions: Older people at risk of abuse will be better supported if staff work within this policy 8.5 Sexual Orientation no 8.6 Religion or Belief no 8.7 Transgender no 8.8 Maternity & Pregnancy no 8.9 Marriage & Civil no partnerships 8.10 Carers*Our Trust no requirement* 9 What monitoring arrangements are you implementing or already have in place to ensure that this policy/procedure/strategy:- 9a Promotes equality of opportunity for people who share the above protected characteristics; Review of datix which indicate safeguarding alerts. 9b Eliminates discrimination, harassment and bullying for people who share the above protected characteristics; As above 9c Promotes good relations between different equality groups; As above 9d Public Sector Equality Duty – “Due Regard” Have you developed an Action Plan arising from this assessment? As above 10 11 No Assessment/Action Plan approved by Signed: Date: Title: 12 Once approved, you must forward a copy of this Assessment/Action Plan to the Equality and Inclusion Team: inclusion@swyt.nhs.uk Page 12 Equality Impact Assessment Questions: Evidence based Answers & Actions: Please note that the EIA is a public document and will be published on the web. Failing to complete an EIA could expose the Trust to future legal challenge. If you have identified a potential discriminatory impact of this policy, please refer it to the Director of Corporate Development or Head of Involvement and Inclusion together with any suggestions as to the action required to avoid/reduce this impact. For advice in respect of answering the above questions, please contact the Director of Corporate Development or Head of Involvement and Inclusion. Page 13 Appendix C - Checklist for the Review and Approval of Procedural Document To be completed and attached to any policy document when submitted to EMT for consideration and approval. Yes/No/ Unsure Title of document being reviewed: 1. 2. Title Is the title clear and unambiguous? YES Is it clear whether the document is a guideline, policy, protocol or standard? YES Is it clear in the introduction whether this document replaces or supersedes a previous document? YES Rationale Are reasons for development of the document stated? 3. 4. Is the method described in brief? YES Are people involved in the development identified? YES Do you feel a reasonable attempt has been made to ensure relevant expertise has been used? YES Is there evidence of stakeholders and users? EMT consultation with Content Is the target unambiguous? 6. YES Development Process Is the objective of the document clear? 5. Comments population clear YES and YES Are the intended outcomes described? YES Are the statements clear and unambiguous? YES Evidence Base Is the type of evidence to support the document identified explicitly? YES Are key references cited? YES Are the references cited in full? YES Are supporting documents referenced? YES Approval Does the document identify committee/group will approve it? which If appropriate have the joint Human Resources/staff side committee (or equivalent) YES N/A Page 14 Yes/No/ Unsure Title of document being reviewed: Comments approved the document? 7. 8. 9. 10. 11. Dissemination and Implementation Is there an outline/plan to identify how this will be done? YES Does the plan include the necessary training/support to ensure compliance? yes Document Control Does the document identify where it will be held? YES Have archiving arrangements for superseded documents been addressed? yes Process to Monitor Effectiveness Compliance and Are there measurable standards or KPIs to support the monitoring of compliance with and effectiveness of the document? YES Is there a plan to review or audit compliance with the document? YES Review Date Is the review date identified? YES Is the frequency of review identified? If so is it acceptable? YES Overall Responsibility for the Document Is it clear who will be responsible implementation and review of the document? YES Page 15 Appendix D - Version Control Sheet This sheet should provide a history of previous versions of the policy and changes made Version Date Author Status Comment / changes 1 June 2008 Director of Corporate Development Final Final version approved by Trust Board 2 March 2009 Director of Corporate Development 3 March 2010 Specialist Adviser safeguarding adults Final draft Changes made following review and subsequent recommendations made during NHS LARMS review 4 March 2012 Specialist Adviser safeguarding adults Draft 1 Changes made following services from NHS Barnsley transfer of 4 April 2012 Specialist Adviser safeguarding adults Final Version Changes made following services from NHS Barnsley transfer of 5 July 2014 Specialist Adviser safeguarding adults Draft 3 Changes made following legislation and guidance changes to 5 Septem ber 2014 Specialist Adviser safeguarding adults Final version Changes made based on changes in legislation and feedback from colleague’s within the Trust and CCG. Changes made to ensure clarity on superseded or replaced documents and to reflect change in guidance for 2009/10 Page 1